20250929Amended Formal Complaint.pdf

RECEIVED
September 29, 2025
Brenda Charles IDAHO PUBLIC
2060 W. Shy Creek PI UTILITIES COMMISSION
Nampa, ID 83686
Phone: [phone]
Email: brendacharles19839yahoo.com
September 18, 2025
Idaho Public Utilities Commission
Attention: Commission Secretary
11331 W. Chinden Blvd, Bldg 8, Suite 201-A
Boise, ID 83714
Re: Amended Formal Complaint - Brenda Charles v. Idaho Power
Company
Dear Commission Secretary,
Enclosed please find my **Amended Formal Complaint (Second Revision)** in the matter of Brenda
Charles v. Idaho Power Company, Case No. IPC-E-25-26, in compliance with Order No. 36739 issued
on August 27, 2025.
This amended filing is submitted within the 30-day deadline set forth in the Order and is intended to
address the deficiencies identified by Commission Staff. Specifically, the amended complaint cites the
applicable statutes, Commission rules, and tariffs allegedly violated, including Idaho Code §§ 61-612,
61-618, and IDAPA 31.01.01.054.
1 respectfully request that the Commission accept this amended complaint, issue a Summons to Idaho
Power Company, and provide me with any further instructions regarding the next steps in this
proceeding.
Thank you for your attention to this matter.
Sincerely,
Brenda Charles

BEFORE THE IDAHO PUBLIC UTILITIES
COMMISSION
IN THE MATTER OF THE FORMAL COMPLAINT OF
BRENDA CHARLES, COMPLAINANT
AGAINST
IDAHO POWER COMPANY, RESPONDENT
CASE NO. IPC-E-25-26
UPDATED AMENDED FORMAL COMPLAINT (SECOND REVISION)
Submitted by:
Brenda Charles
2060 W. Shy Creek PI
Nampa, ID 83686
Phone: [phone]
Email: [e-mail]
Date: September 18, 2025
1. Parties
Complainant: Brenda Charles, 2060 W. Shy Creek PI, Nampa, ID 83686.
Respondent: Idaho Power Company.
2. Facts
- Idaho Power wrongfully billed me for charges that are not my responsibility.
- Idaho Power wrongfully disconnected or threatened to disconnect my electric service for
non-payment, even though the charges are disputed.
- Idaho Power failed to provide me with proper notice before transferring another customer's
bill/account balance to my account.
- On or about September 10, 2024, 1 was approved for energy assistance in the amount of$1,210, but
these funds were never applied to my Idaho Power account.
-The electrical wiring in my residence appears to have been installed improperly, creating unsafe
conditions. Idaho Power is responsible for ensuring safe service connections and compliance with
safety codes.
- I have children in my household who rely on medical equipment (breathing machines) that require
continuous electricity. Without electricity, their lives could be endangered.
- Idaho Power failed to obtain my signed agreement or consent to accept responsibility for payment of
another customer's bill before transferring it to my account.
-The notice Idaho Power provided did not meet Commission requirements. It failed to contain the
required information about the basis for the charges, the right to dispute, and timelines for response.
- Electrical problems occur frequently in my residence, particularly with my furnace and air conditioning
system. I have had to replace multiple circuits every year.
- Most recently, my air conditioner's condenser failed and burned out, even though it had already been
replaced last year. These repeated failures show unsafe or unstable electrical service, which is

dangerous and financially burdensome.
3. Violations of Law and Rules
Idaho Power's actions violate:
- Idaho Code § 61-612— requiring utilities to furnish adequate, safe, and reasonable service and
comply with Commission rules and tariffs. The unsafe wiring and risk to my household violate this duty.
- Idaho Code § 61-618—making it unlawful for a utility to charge, demand, or collect unjust or
unauthorized amounts. Failing to apply$1,210 of approved energy assistance to my account and billing
me instead constitutes unjust charges.
- IDAPA 31.01.01.054—requiring a complaint to identify violations of statutes, Commission orders,
rules, or tariffs; Idaho Power's transfer of another person's bill and subsequent collection/disconnection
violates controlling law.
- IDAPA 31.21.01.701-703 (Utility Customer Relations Rules) —requiring proper written notice before
service disconnection, protections for customers with medical conditions, and procedures for billing
disputes. Idaho Power failed to follow these protections when it billed me improperly and threatened my
household's medical safety.
- Idaho Power violated Commission rules by transferring another customer's balance to my account
without a written agreement signed by me accepting responsibility for that bill.
- Idaho Power violated Commission notice requirements by failing to provide the full contents required
in written notice before attempting collection or disconnection.
4. Relief Requested
-That the Commission order Idaho Power to remove all improper charges and billing transfers from my
account.
-That Idaho Power be required to apply the$1,210 in approved energy assistance funds to my account
as of September 2024.
-That Idaho Power be prohibited from disconnecting my service while this dispute is pending and while
medically necessary equipment is in use at my residence.
- That Idaho Power be required to inspect and correct any unsafe or improperly installed wiring
connected to my residence to ensure safe service.
-That Idaho Power comply with the medical necessity protection rules to ensure continuous electric
service for my children's health and safety.
-That the Commission require Idaho Power to follow all applicable statutes, Commission rules, tariffs,
and notice requirements before imposing charges or threatening disconnection.
-That the Commission require Idaho Power to conduct a full inspection of the electrical service
provided to my residence, including power quality, wiring safety, and equipment protection, to ensure
compliance with safety standards and to prevent repeated failures of essential household equipment
such as the furnace and air conditioning system.
-Any other relief the Commission deems just and proper.
Certification
I, Brenda Charles, declare under penalty of perjury that the foregoing facts are true and correct to the
best of my knowledge.

Date: September 18, 2025
Signature:
Brenda Charles